Early in 2018, a calendar-year corporation engages your services to prepare its federal income tax return for 2017. It informs you that it was created and capitalized in (hopefully) a351 transaction employing only common stock. As you speak with the CFO, you learn the following with respect to the 4 participating shareholders:

1) Shareholder A received 5% of the stock in exchange for certain information in her custody related to the industry in which the corporation would be operating

2) Shareholder B received 5% of the stock in exchange for his provision of legal organizational services

3) Shareholder C received 30% of the stock in exchange for raw land; 2/3 of that stock was sold by Shareholder #3 immediately after the attempted 351 transaction

4) Shareholder D received 60% of the stock in exchange for cash.

Consider only the351 requirements of "control" and "property".

a. Why may351 treatment be in jeopardy? (do NOT analyze the situation here; do so later; here only state the basic concern(s))

b. To resolve this/these concern(s), what questions do you need to ask with respect to:

1. Shareholder A

1. Shareholder C